Transport Committee on May 14th, 2007

[The Chair, Conservative, Merv Tweed]

Order. Thank you, and good afternoon, everyone. Welcome to the Standing Committee on Transport, Infrastructure and Communities. This is meeting 51. Pursuant to the order of reference of Tuesday, November 7, 2006, we are here to study Bill C-6, An Act to amend the Aeronautics Act and to make consequential amendments to other Acts.

This is our last hour of witnesses. Joining us today are Mr. Paul Carson, flight technical inspector, certification and operational standards; and Mr. Hugh Danford, former civil aviation inspector.

I think you've been advised as to the drill here--seven minutes for introduction and then we'll have questions around the table.

If you're ready, Mr. Carson, I'll ask you to proceed.

[Paul Carson, Flight Technical Inspector, Certification and Operational Standards, Transport Canada, As an Individual]

Thank you very much.

I'm going to read initially from what I've written. It's a little longer than seven minutes, but I'll cut it short.

I would like to personally thank the steering committee for taking the time to let me appear before you today to express my ideas. It should be made clear that I am here on my own accord, speaking as Citizen Carson, not Inspector Carson, or Captain Carson, or Dr. Carson--all of these euphemisms we attach to ourselves to make it easier for others to deal with us.

It should also be made clear that I personally am a believer in safety first and pretty much everything else second, including profit. I can unequivocally state that I am a supporter of concepts like SMS.

First, what is my background? It includes about 40 years of work experience, 30 of them in aviation; four university degrees, one in aeronautical engineering, including a PhD in applied math; approximately 10,000 hours of flying, all civilian, including for two prime ministers and several CEOs of a couple of Canada's largest corporations. I have been any number of things in my aviation career, including flight safety officer and occupational health and safety officer at a couple of companies. Many years ago I took a course on system safety at the University of Southern California in San Diego, and just recently I took TCCA's course on SMS.

SMS is not a new concept. It has been around in various forms for many years. There are many things about an SMS program that would be highly beneficial. It is certainly a better idea to have everyone in any organization safety conscious instead of vesting that job solely in an individual like me, for example, with minimal staff, as many air operators have done in the past.

Having the onus put on an organization to have them operate within a safety-minded culture is certainly better than operating any other way. However, although the concept of safety in itself can mean very specific things, it is sort of like a religion: you either believe in it or you don't. By that I mean you either believe you can operate safely within the rules and do the job cost effectively or you believe the rules you have been asked to follow are merely suggestions and the only thing that matters is the bottom line. Safety is expensive. Far too many aviation companies believe the regulations are just that, guidelines, and it is okay to bend them to the limit, if not outright break them, as long as nothing goes wrong or you don't get caught.

Hence the subject of my visit. In front of you today is something that I think is missing, in part, in order to make SMS work. And I would like to see it work.

Pilots need a nationwide self-governing, self-regulating professional association to which all professional pilots--and I mean those flying for hire or reward--must belong. In view of the changes presently occurring in the aviation industry with the introduction of SMS--a form of what I like to call “supervised” self-government and self-regulation for the air operator industry--they need it to provide a pilot input to balance company management, government regulators, and clients in the dynamic bargaining process that determines the industry environment. They need it to provide them with real whistle-blowing protection, since they will be the ones under SMS who really know what will be going on in the future, in my opinion. They need it to set standards for technical education required for the various types of aviation jobs, from entry-level commercial pilot to captain of high-performance passenger-carrying jet. They need it to ensure they receive the proper ongoing education to enable them to do each job with confidence and competence as they progress through their careers. Ethics will be taught and examined.

When I first wrote this paper, I talked only about pilots, since I am a pilot, but I would now extend the same concept to licensed maintenance engineers and certificated dispatchers. Also, for the record, I sent my ideas twice through TCCA's issues reporting system, and then in the form of a discussion paper to my current director and to the association to which I belong. So I have tried to communicate with a number of people.

What is missing from SMS is a check and balance system, in my opinion. It is one thing to give supervised self-government and self-regulation to an air operator, to the management, and the owners of a company, but it is an oversight not to give the same thing to the licensed pilots, maintenance engineers, and dispatchers who do the work. For example, without the licensed pilots employed by the company, the company cannot operate. These licensed individuals need their own self-governing, self-regulating association that will provide them the protection they very much need from any unscrupulous employer on those occasions when an employee feels the need to blow the whistle on the company for safety violations. We've had incidents of this in the past, recently in Toronto. This body needs to be the licensing authority for these individuals, not the governing authority, in my opinion.

Other professions have self-regulating associations that influence the environment their members work in, set professional qualification standards, and continue to judge their professional competency. Such professional associations also intervene on behalf of their members or the general public, if necessary, when there are security and safety concerns. Engineers, doctors, and lawyers all have self-regulating associations, as do other professions.

Anyone who wishes to practise one of these professions must satisfy the standards set by the association and must be a member in good standing. These associations also discipline members who have failed to meet the obligations and responsibilities of their profession. No one gets a free ride.

Regarding common interests, many professional pilots—again, those who use their licence to fly for hire or reward—have no opportunity to belong to any association. I'm aware of only three major trade associations for pilots in Canada: the Canadian Federal Pilots Association, for pilots employed by the federal Department of Transport, to which I belong; the Air Line Pilots Association, Canada, ALPA Canada, for pilots employed by various regional airlines; and the Air Canada Pilots Association, ACPA, for a grand total of approximately 4,000 pilots.

The last time I checked, over 19,000 aviation licences, belonging to commercial and airline transport pilots, are in force in Canada, enabling their holders to offer their services as professional pilots. The vast majority of professional Canadian pilots, who work as flight instructors, bush pilots, charter pilots, corporate pilots, agricultural spray pilots, air ambulance pilots, or any other of the many varieties of flying jobs in aviation, have no professional association.

I could go on at length; I'm limited in my time here.

For those who belong to a professional association, say, regarding the law.... If you read this section on education, you'll understand a lot more about where I'm coming from because this forms a lot of it. It's a couple of pages, and I have to skip over to a section entitled, “Other Functions”. If you read that, then you'll appreciate the next comment.

I dealt at length with knowledge and licensing as a responsibility of the proposed professional pilots association, because I feel it is the foundation upon which any claim to professionalism must be made. That's essential. However, besides knowledge and licensing, the professional pilots association would take responsibility for representing pilots and providing specialist assistance—say, in accident investigation—and for encouraging and even sponsoring research into airframe, engine, and system design, and into the civic aspects of aviation personnel management and interpersonal behaviour, something that today we call the human factors.

Another important function would be presenting the pilots' point of view as a group on proposed legislative changes, as part of the consultation process with industry owners and operators. Company management is judged by whether they show a profit at the end of the year. While pilots are by no means immune to the profit motive, they are also aware that the high salaries they may earn mean little when you arrive first at the scene of an accident.

Membership in a professional pilots association must be mandatory for all pilots who fly for hire or reward, just as professional engineers must belong to their provincial professional association if they are paid for their services as engineers. Such professional membership must be a legal, regulatory requirement with no waivers or exceptions possible. Voluntary membership in a professional association would not be sufficient.

In conclusion, to accomplish the changes I have suggested will take organization, experience dealing with government, and certainly familiarity with the aviation industry, at the very least. The existing pilots trade associations could act as the nucleus around which a professional association, such as I have outlined above, could grow.

A professional association also needs legal status. We must have a federal professional pilots act, or something similar, to give the association legal existence and the powers it will need.

As well, federal empowerment will address our obligations under the Convention on International Civil Aviation. The remaining requirements would be hard work and some dedication.

Thank you for listening.

I'm now prepared to take any questions.

[The Chair, Conservative, Merv Tweed]

Thank you, Mr. Carson.

Mr. Danford.

[Hugh Danford, Former Civil Aviation Inspector, Transport Canada, As an Individual]

I'd like to thank the committee for this opportunity to finally speak on a subject that is well known to me.

Let me first give you my background in aviation. My career spanned 30 years in aircraft operation. Most of my 9,000 hours were on Twin Otter aircraft on wheels, floats, and skis. I've flown for small airlines and corporations in the Arctic, Antarctic, North Africa, and the Middle East. My last posting was in the Maldives, before TC's enforcement division in Ottawa hired me in May 1998.

During my early days at TC, I was involved with the basic aviation enforcement course that all inspectors were required to take as a prerequisite to obtaining their delegated authority under the minister. I gave the course introduction and included, among other topics, the report of the Commission of Inquiry on Aviation Safety, the Dubin report; the Commission of Inquiry into the Air Ontario Crash at Dryden, Ontario, the Moshansky report; and Swanson v. Canada, arctic wings and rotors. Managers were not required to take this training, even though they held a delegated authority.

I soon realized that the information I was presenting the attendees did not reflect the actual situation or expectations of the inspectors in exercising their delegated authority. It appeared to me that management's main concern was to get out of the enforcement business and the liability issues inherent in that responsibility. We were not practising what we preached.

I transferred to the system safety branch, where one of my duties was to sell the SMS to the regions. They balked. I was also tasked to study and report on air crashes. I joined the work group called the TRINAT, which was an initiative by TC's international aviation branch. The group was made up of representatives from Canada, the U.S., and Mexico. We were tasked with analyzing 276 crashes to determine root causes.

The criterion was all aircraft with 10 to 200 seats. The breakdown was twenty for Canada, seven for Mexico, and the remaining files were from the U.S.

Of the 20 Canadian crashes, 25% had a root cause of “lack of regulatory supervision”. This was not our interpretation; this information was quoted from TSB reports. I do not know what happened to the TRINAT study after I left TC.

One of the crashes we reviewed in the group was the Davis Inlet crash on March 19, 1999, TSB report number A99A0036. The crash, lack of investigation, and the eventual cover-up were indicative of the malaise that permeated Transport Canada.

Upon further investigation into the file, I discovered that the pilot had four previous crashes and a multitude of fines, suspensions, and letters of counselling. Some of the comments in the pilot's enforcement file were as follows:

March 1991:

Pilot had enough hard violations pending. No further action. Not in public interest to spend more time on this possible violation

May 1991:

Mr. XX has a habit of ignoring IFR procedures and I am anticipating that with fines imposed he will get the message.

That was a $250 fine, by the way.

June 1991:

Mr. XX will probably be a repeat offender.

August 1991:

Flagrant disregard for established rules and procedures caused an accident that could have produced fatalities.

April 1993:

Previous sanctions have not changed this individual's method of operating, and I do not think this will either. We will hear from this gentleman again.

After the pilot's last crash, which killed his copilot, on March 19, 1999, there was no enforcement investigation, as required by Transport Canada and ICAO. The Transportation Safety Board confidential preliminary report contained reference to the pilot's flying record; the final report did not. His licence was not suspended by TC until three years later.

As a result of the crash, the TSB issued recommendation A01-01, which stated:

The Department of Transport undertake a review of its safety oversight methodology, resources, and practices, particularly as they relate to smaller operators and those operators who fly in or into remote areas, to ensure that air operators and crews consistently operate within the safety regulations.

This was the most important recommendation since the Moshansky commission.

On July 13, 2001, Transport Minister David Collenette stated in a press release:

In advance of the TSB recommendation, Transport Canada initiated a phased study to review safety oversight methodology, resources and practices, with the goal of ensuring that air operators and crew consistently operate within the safety regulations

It goes on to say:

Transport Canada will respond to the findings of that study as the next step in continually improving the safety of the air taxi sector.

This study is known as the DMR report. The DMR report was impossible for anyone to understand, so it was reworked and reissued as DMR 2. The total cost was $750,000. The final draft copy was dated September 10, 2001, and was to be delivered the next day in Victoria—that was 9/11. For obvious reasons, the issue was shelved.

I was blocked at every angle from trying to get a copy of the DMR that had already been offered up to the Privy Council as satisfying the recommendation. I was told in writing by a manager at head office that the DMR was a failed document, and management didn't want us referring to it.

After finally getting my hands on part of the DMR report, I could not find any reference to remote areas. The more I searched for the rest of the report, the more isolated I became, until my health was brought into question. I was sent to Health Canada for a psychiatric assessment. After nine months on leave without pay, I resigned from TC.

Davis Inlet is an important study of what ails the regulatory program. The crash, investigation, and the eventual cover-up were indicative of the malaise that permeates TC. Inspectors are not allowed to do their job. TC knew the pilot was going to reoffend. They did nothing and somebody died.

It is my opinion, and I quote from Swanson, that:

Transport Canada officials negligently performed the job they were hired to do; they did not achieve the reasonable standard of safety inspection and enforcement which the law requires of professional persons similarly situated

See Swanson v. Canada.

I think the SMS concept is workable, but it can only work if there is a strong enforcement component. I get nervous when reports are mandatory and confidential.

Everything I have stated here can be backed up with documents.

[The Chair, Conservative, Merv Tweed]

Thank you, Mr. Danford.

Mr. Volpe.

[Joe Volpe, Liberal, Eglinton—Lawrence, ON]

Thank you very much.

Mr. Danford and Mr. Carson, thank you for coming, even if it is late in the hearing process.

I found that your presentation—which I read before I came here, so it wasn't that I wasn't paying attention when you were speaking—was instructive for a couple of reasons. I hope you will correct me if I have misunderstood or misinterpreted what you said.

I think both of you dealt with the issue of the highest level of safety established by the minister, or the acceptable level of safety by the minister. I wonder whether you would spend a moment distinguishing between two.

As I understood both of your presentations, you were really talking about liability: that the minister or Transport Canada through this SMS system, as proposed, unamended, would put off to the industry the responsibility to set levels of safety and be liable for them. In one, it says the minister continues to be liable for all levels of safety, with an obligation--it's an imputed obligation--that there will always be improvements in the levels of safety.

So what is acceptable today would be the highest standard today, but it may not be the highest standard tomorrow. An acceptable standard tomorrow must, of necessity, be higher.

Could you spend a moment distinguishing the two for me?

[The Chair, Conservative, Merv Tweed]

Mr. Danford.

[Hugh Danford]

No. I am confused.

My issue is the lack of regulatory supervision, and it's always there. We had an airline come up from California and do 50 internal flights flying hockey teams around, and there was no enforcement action on that. We hear those things every day, where management does not allow the inspectors to do their jobs. But there are basic fundamentals in doing your job, and that's creating a safe environment in the cockpit and in the company.

If you have people like this pilot, there's no provision to take a pilot's licence away in Canada. You lose your licence if you lose your medical. Other than that, it's in the pubic interest under the Aeronautics Act. So we don't have a system, as Paul suggests, of an organization of pilots—that might help—but there is no provision.

I'll give you a good example. There's a pilot in Sudbury who was flying down in Florida. He lived in Florida most of the time, so he got an American licence based on his Canadian one. The Americans have a provision called airman re-examination, where if somebody sees you doing something that's not safe, you're going to get a letter and you're going to have to talk to somebody, write to somebody, or do a flight test.

This particular pilot did a flight test with an FAA inspector and had his American licence taken away from him. He continued to fly with his Canadian licence because we don't have that provision. We cannot see a dangerous pilot and do anything about it.

[Paul Carson]

To carry on for Hugh, I'm a professional engineer also, and maybe some of you in this room are engineers. Every month I get a magazine sent to me with the blue pages. Those blue pages show where some engineer has done a no-no and has been sanctioned, either financially or with his licence--which is a privilege, ladies and gentlemen. His licence is temporarily, and sometimes permanently, removed, as I think is the case with many professional associations. I've talked to a few doctors, and they certainly have their own internal system. When people do things that are inappropriate, they have a system for dealing with it. And that's what I am proposing.

In the future, if we go towards a system of SMS, again, I personally support the concept of it.... A licence is a privilege; it's not a right. It's the licensed people out there doing the work who know what's going on. They need that whistle-blowing protection to be able to report things comfortably so that it becomes normal to do so.

Without overstating the case, in a couple of companies I worked for in the past, I put my job on the line at least twice that I can recall. I simply wouldn't do things that I guess other pilots in the company were doing, such as going below limits. I could do it, but I thought it was unwise. I didn't consider myself good enough to be able to fly like that or to take an airplane that was in violation of its limitations from point A to point B. I can distinctly remember a case where that happened. I refused to do it, and I put my job on the line. Maybe I was lucky, but I felt I had other qualifications to do other things. Other pilots feel they can't and that they have to do certain things they don't want to do.

I don't know if that answers your question. You were talking about the difference between an absolute level of safety, an ultimate level of safety, and some acceptable level of safety. I think I would agree with you that it's a very difficult question to answer.

[Joe Volpe, Liberal, Eglinton—Lawrence, ON]

The government has said in the past that to have an ongoing system of surveillance--and I hope I'm not misrepresenting the case--might be a little too costly. It would require an army of inspectors to inspect all the planes that take off from Canadian soil. I'm wondering whether you find that to be an acceptable position or whether you would ask us to consider a system that is not too different from the Canadian Food Inspection Agency. It sends out health inspectors on food products that are to be introduced into the consumer market.

[Paul Carson]

I'll tell you, the day that inspectors stop inspecting, I'll stop flying; the day that meat inspectors stop inspecting meat, I'll stop eating meat; the day drug inspectors stop inspecting drugs, I'll stop taking drugs. I think it's costly--there's no doubt about it.

I proposed what I did because the people doing the work will know where the problems are. If they have a way of reporting deficiencies without the fear that every time they do it they put their careers on the line, I think that would be better. In engineering we call it whistle-blowing. Yes, it's costly. Safety is expensive, as I said, but I stand by my remarks.

[Hugh Danford]

When I worked in the Arctic there was always the fear of an inspector hiding behind every 45-gallon drum. Then when I joined Transport, I realized they weren't. They don't do that. They don't want to regulate.

Air Transat is a perfect example of how an SMS system would have worked, could have worked, and it should have been studied to death. That whole thing was luck. If that airplane had gone another 10 minutes before the fuel chafed through the fuel line, they'd all be dead. Nobody would be here right now talking about this; it would be all new people. That wasn't studied. There was no enforcement investigation into that as required by ICAO. They cut the cheque over the phone and then they did the enforcement investigation. It was just a paper exercise on one of the biggest potential disasters we'd ever had. It was sheer luck.

[The Chair, Conservative, Merv Tweed]

Monsieur Laframboise.

[Mario Laframboise, Bloc, Argenteuil—Papineau—Mirabel, QC]

Thank you, Mr. Chairman.

One of the great dilemmas we face with Bill C-6 is trying to strike a balance between regulatory overview, that is maintaining a proper inspection system, and the safety management system, which is supposed to provide added security. The problem lies in wanting to maintain an adequate safety system.

Mr. Danford, you are an inspector. I'd like you to tell me what your job entails and how it is likely to change if we verify management systems instead of carrying out direct inspections of pilots or aircraft. What is your position on this matter?

[Hugh Danford]

My position is that you can't get rid of the audit procedure. You have to have audits. Just as the Auditor General is going to audit Transport Canada, you have to have those audits. They need to be done. They've been watered down. The whole program was watered down. Dryden was the birth mother of the audit system.

When I took the audit course in 2000, there was no mention of Dryden. The whole chapter, the whole module on liability, crown liability, Dubin, and Dryden, was removed. When I sat in that course, there were about 30 people, and we all identified ourselves. I identified myself as an enforcement investigator, and that was it, I was singled out for the rest of the course.

The man who was giving the course, in his years of doing audits, had never referred one issue to enforcement. The concern was losing the audit. We don't want to lose the audit. I never understood what that meant, but my job was just to fill in paper and send it into the manager. I was at head office, so I wasn't in the field. We were more writing policy and procedure and delivering the courses on crown liability.

[Mario Laframboise, Bloc, Argenteuil—Papineau—Mirabel, QC]

I will put the same question to Mr. Carson.

What is your opinion of the regulatory oversight system? Do you think we need to maintain an effective parallel regulatory inspection system in order to carry out on-site inspections while at the same time promoting the safety management system?

[Paul Carson]

Okay. I really didn't want to get into this debate, but since I've been asked the question, I will try to answer it as well as I can.

This is my personal opinion, sir. I feel that the SMS concept is a really good one. I think companies out there that demonstrate maturity and that can demonstrate that they have a system that is not only valid but effective, an SMS system, perhaps should be given some kind of let so that they wouldn't be “audited” as much or as often. I think for companies out there that cannot demonstrate that they have a valid and effective SMS, there has to be more regulatory action, more audits, more on-site inspections done.

What I'm saying is that perhaps SMS is being mandated. I probably would have made it voluntary, so that some kind of leeway on inspections or something, some kind of gold star would be given to those systems, those airlines, and those operators that would have taken the system and implemented it on their own and made it work and demonstrated that they had a valid system. There are ways of demonstrating validity. Also, they would have to show that it was effective, and there are certainly ways of doing that. You can do it by collecting data. It's a data-driven system, so you probably have to do it mostly statistically, so that you have data, and you're not using somebody's opinion. Then, at that point, you move on and you put your limited resources—and they are limited—into companies that we know need additional oversight. I think a combination of that kind of system would have been much more effective, but that's just my personal opinion.

I hope I've answered your question.

[Mario Laframboise, Bloc, Argenteuil—Papineau—Mirabel, QC]

Yes, thank you.

We have a duty to defend the interests of people who, like us, are not familiar with the aeronautics industry. The problem lies in the fact that new airlines appear on the scene and then disappear just as quickly, often within the space of a year. Under the circumstances, I have some serious issues with giving companies sole responsibility for doing safety checks.

SInce you have some experience in this area, could you enlighten me a little, Mr. Danford?

[Hugh Danford]

I look at it like trying to run a neighbourhood watch without a cop car. You can't do it. You have to have oversight. And it can't be, as I think I heard the other day, where Mr. Reinhardt was going to work with one airline to look at another. I think that's how I understood the text. If that is the case, that's not workable at all. You need to have people who can come forward in the SMS without fear of reprisal. That's very hard to do when there's money associated and safety associated....

I think the groundwork that has to be done to change the regulatory process is to get more people working for Transport Canada who have actually worked in the industry. Most of the management have never worked in aviation. Merlin Preuss has never worked in aviation; he flew weapons platforms. So all those managers.... We have a director who used to be a tank driver. He doesn't have to take the course to give him the delegated authority. They refuse to take those courses.

So you have to start with Transport knowing what they're doing before they start making the industry do something that.... It's a big change. I like cop cars around the corner.

[The Chair, Conservative, Merv Tweed]

Mr. Julian.

[Peter Julian, NDP, Burnaby—New Westminster, BC]

Thank you, Mr. Chair.

Thank you to our witnesses for coming forward.

Mr. Danford, you mentioned having a partial copy of the DMR report. Is that something you could table with the committee?

[Hugh Danford]

The Auditor General has this document. The Public Service Integrity Office has it. Everyone has it except Virgil Moshansky, I think. But I'll give this up.

When I first created this document, I didn't know the dead guy's name. I was so ostracized that I was afraid to ask. I did a lot of research into this file. I know that the pilot who crashed this airplane and the one who was along for the ride took the crew resource management course that Transport Canada had developed. According to the TSB, there wasn't any reference to anything they learned in that course. It was the same stuff. The young guy sits on his hands and keeps his mouth shut and he watches the older guy trying not to kill him. So that's the document.

As far as I'm concerned, Transport Canada lied to the Privy Council. They lied to the Transportation Safety Board. The DMR report is a failed document. I believe they'll do anything rather than regulate.

[Peter Julian, NDP, Burnaby—New Westminster, BC]

Thank you for agreeing to share that.

I appreciate both of your testimonies. In a very real sense it wraps up what we've been hearing, which is folks saying that SMS would work in theory. But looking at the practical sides of the lack of enforcement, the lack of support, and the cutbacks we're seeing essentially raises real issues about the final result if Transport Canada continues cutting back on regulation and ending audits at the same time as they're promoting SMS.

I want to give you a quote from Justice Moshansky. You've both referred to him. When he appeared before us on February 28, he said:

Today, 18 years after Dryden, history is repeating itself, only worse. Cost-cutting is again in vogue at Transport Canada and has been for some time. Transport Canada management have publicly admitted this. Regulatory oversight is not being merely reduced. Except for limited focused audits, it is being systematically dismantled...

—regulatory oversight is being systematically dismantled—

...under Bill C-6. All of this is occurring in the face of a predicted doubling of the size of the aviation industry by 2015, as per Transport Canada's own estimates.

I would like to ask both of you how you react to Justice Moshansky's comments about Transport Canada's cutbacks on regulatory oversight.

[Paul Carson]

To the best of my knowledge, the audit program that I've taken myself a couple of times--and I've been on two national audits--has been disbanded or cancelled. I guess in a sense you'd have to agree with Justice Moshansky.

It is my understanding when SMS was introduced that it was going to be a replacement for that. People have argued that it's a layer of regulation on top of other regulation. How can you cancel an audit program and then say the latter? It just doesn't make any sense. I hadn't taken course 51 or 52, but I had read everything that came across my desk. We have an electronic file system in Transport. It's not so good sometimes, but if you work it hard enough, you can make it work. I read everything I could get my hands on, because I was curious.

I think the original intent was to replace existing legislation, in some way, for valid reasons, from a cost point of view. Maybe that's changed, but I don't know how you could cancel the audit program. I guess that's been pretty much documented to you gentlemen and ladies. This just doesn't make sense. I hope I've answered that question.

[Peter Julian, NDP, Burnaby—New Westminster, BC]

Thank you.

Mr. Danford.